Our agency would be in favor of increasing the requirements for the staff providing the direct services.  Development of a category similar to QMHP, QIDP, or QSAP, for the practitioners of Behavioral Treatment services could be beneficial in improving the knowledge of those providing the direct services.   Requiring direct care staff to have specific experiences with the ID/D population and/or behavioral interventions would be consistent with what regulatory requirements exist in other program areas (e.g. Intensive In-Home, ID/D Crisis Stabilization).

Likewise, specific training developed and required by DMAS or DBHDS would also be welcomed, if offered in multiple sites and dates across the state.

We would not be in favor of requiring a BCBA to be the supervisor of Behavioral Treatment services rather than a LMHP.  In larger areas employing or contracting with a BCBA may be feasible, however this would essentially eliminate Behavioral Treatment Services in the Southwestern region of the state.  In addition, BCBA credentialing is an excellent professional license for Behavioral Interventions, but does not provide the same training in assessment of underlying Mental Health symptoms that are known to co-morbidly exist in the ASD and ID populations.